AB 688 adds section 14132.726 to the Welfare and Institutions Code and directs the Department of Health Care Services to produce publicly available analyses of Medi‑Cal telehealth utilization beginning in 2028 and every two years thereafter. The statute requires the department to draw on Medi‑Cal claims and other available data and to publish the information either as updates to its existing Biennial Telehealth Utilization Report or as a separate report.
The reporting mandate focuses on detailed, claims‑based breakdowns — visits per member months, modality mix for new and established patients, common CPT codes, specialty categories (including mental health and dental), and utilization among high‑use members — and requires disaggregation by geography, demographics, and social‑determinants proxies. By creating a recurring, public dataset on telehealth use in California’s Medicaid program, the bill aims to give policymakers, plans, providers, and researchers the evidence they need to detect disparities and shape program responses.
At a Glance
What It Does
Starting in 2028 and every two years after, the bill requires the Department of Health Care Services to produce publicly available analyses of Medi‑Cal telehealth utilization using Medi‑Cal and other state data. The department can publish these analyses as part of its existing Biennial Telehealth Utilization Report or in a different applicable report.
Who It Affects
DHCS will run the analyses and publish the reports; Medi‑Cal managed care plans and providers will be the primary data sources, and counties that deliver specialty mental health services and outpatient dental care will be implicated. Researchers, advocates, and state policymakers will be primary users of the published data.
Why It Matters
This creates a statutory expectation for routine, disaggregated monitoring of telehealth in California’s Medicaid population — information that has been patchy to date. The data can inform equity interventions, managed care oversight, reimbursement decisions, and program design for telehealth services.
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What This Bill Actually Does
AB 688 tells the Department of Health Care Services to produce and publish recurring analyses of how Medi‑Cal beneficiaries use telehealth. The department must rely on Medi‑Cal administrative and claims data and may supplement that with any other data it has access to.
The first required analysis is due in 2028, and the law then requires updates every two years; the department can fold the new analyses into its existing Biennial Telehealth Utilization Report if it prefers.
The statute specifies a set of utilization measures the department must include: claims‑normalized visit rates (per 100,000 member months), telehealth as a share of all outpatient care, lists of commonly used CPT codes for telehealth encounters, counts of members by number of telehealth claims, and modality breakdowns for new versus established patient telehealth claims. It also singles out several service lines — specialty and nonspecialty mental health, outpatient dental, and common outpatient medical services — so that the report will show where telehealth is being used across different types of care.A core direction of the bill is disaggregation.
Wherever the data allow, DHCS must break down results by geography, demographics (for example, age, race and ethnicity, sex, primary language), aid code group, county size, and managed care plan. The law explicitly permits DHCS to approximate social determinants of health using available indices such as the Healthy Places Index.
Finally, the department must identify additional data elements — including patient outcomes and population‑level health measures — for inclusion in future reports, signaling a move from pure utilization tracking toward outcome‑oriented monitoring over time.In practice, the mandate is primarily analytical and public‑reporting in nature: it does not itself change reimbursement, create new benefits, or impose provider payment rules. But by standardizing which metrics get reported and requiring disaggregation, the bill raises the visibility of disparities and utilization patterns and creates a foundation for future policy or contracting changes based on those findings.
The Five Things You Need to Know
The law requires DHCS to produce Medi‑Cal telehealth utilization analyses beginning in 2028 and then every two years thereafter.
Reports must report telehealth visits per 100,000 Medi‑Cal member months and compare telehealth visits to all outpatient visits.
DHCS must list commonly used CPT codes for outpatient telehealth and report modality mix separately for new‑patient and established‑patient telehealth claims.
The statute demands disaggregation where possible by age group, race and ethnicity, sex, primary language, county (and county size), aid code group, and Medi‑Cal managed care plan, and allows use of indices like the Healthy Places Index to approximate social determinants of health.
The department must identify additional data elements — explicitly including patient outcomes and population health metrics — for inclusion in future reports, but does not require those outcome measures in the initial reports.
Section-by-Section Breakdown
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Reporting schedule, data sources, and public availability
Subdivision (a) sets the operational frame: DHCS must produce the first analysis in 2028 and repeat it every two years. The department is directed to use Medi‑Cal data and any other internal data sources it has access to; the provision also makes the analyses publicly available and permits DHCS to include them in its existing Biennial Telehealth Utilization Report. Practically, this gives the agency flexibility to integrate new work into existing publication cycles while ensuring a statutory floor for frequency and public access.
Core utilization metrics and member‑level breakdowns
Paragraphs (1)–(5) require claims‑based measures: visits normalized per 100,000 member months, telehealth share of outpatient visits, lists of CPT codes, counts of members by telehealth claim frequency, and analysis of high‑use members. These items force DHCS to move beyond aggregate counts to per‑member and per‑claim perspectives, which are useful for spotting concentration of use and measuring whether telehealth is expanding access or being used heavily by a small cohort.
Service‑line reporting and modality details
Paragraphs (6)–(11) require that DHCS report telehealth use in specific clinical domains (specialty and nonspecialty mental health, outpatient dental, and other common outpatient services) and to provide modality breakdowns for new and established patient claims. This directs the agency to produce clinically meaningful slices of the data — not just ‘telehealth overall’ — and to capture how modality choices differ between first‑time and returning patients, which may signal access or continuity issues.
Disaggregation and social‑determinants approximations
Subdivision (c) requires disaggregation wherever the underlying data permit, by demographic, geographic, and social determinants categories. It explicitly authorizes approximating social determinants using indices like the Healthy Places Index. That authorization helps DHCS incorporate place‑based risk measures without creating new data collection mandates, but it also transfers analytic responsibility to the department to map and validate those indices against Medi‑Cal data.
Pathway to outcomes and expanded measures
Subdivision (d) instructs DHCS to identify other data elements — including patient outcomes and population health metrics — for future reports. The provision signals a statutory intent to evolve from utilization reporting into outcome‑focused monitoring, but it stops short of requiring outcome measurement immediately, leaving timing, definitions, and methodology to the department’s future rulemaking and analytic work.
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Who Benefits
- Medi‑Cal members in underserved communities — Disaggregated reporting can reveal geographic and demographic gaps in telehealth access, which advocates and policymakers can use to target interventions to low‑access populations.
- State policymakers and DHCS analysts — Standardized, repeatable telemetry on telehealth gives regulators hard data to inform benefit design, managed care oversight, and potential reimbursement changes.
- Researchers and public‑interest advocates — Publicly available, claims‑based datasets with demographic and SDOH approximations make it easier to study equity, quality, and utilization trends in the Medicaid population.
- Local public health and county behavioral health agencies — Service‑line breakdowns for mental health and dental telehealth give counties actionable intelligence about where telehealth is and isn’t filling gaps in care delivery.
Who Bears the Cost
- Department of Health Care Services (DHCS) — DHCS must allocate analytic, IT, and publication resources to extract, clean, disaggregate, and publish these recurring reports; those costs fall on the department unless funded separately.
- Medi‑Cal managed care plans and providers — Plans and providers will face additional expectations for timely, accurate claims coding and data submissions to ensure analyses are complete and reliable.
- County mental health and dental programs — Counties that deliver specialty services may need to improve claims interoperability and reporting to allow DHCS to produce the mandated service‑line analyses.
- Privacy/compliance teams across state agencies and plans — Producing fine‑grained, disaggregated public reports will require investments in small‑cell suppression, de‑identification techniques, and legal review to manage privacy risk.
Key Issues
The Core Tension
The central dilemma is between transparency and actionability: the law pushes for highly disaggregated, public reporting to surface inequities and inform policy, but claims‑based data, privacy constraints, and limited departmental resources mean the reports may either be too coarse to drive interventions or so aggregated/suppressed that they miss small, high‑need subpopulations; DHCS must balance depth of insight against feasibility and confidentiality.
The statute mandates recurring, public, claims‑based analyses but leaves substantial methodology, privacy, and resourcing decisions to DHCS. Claims data are a blunt instrument for measuring access and quality: they capture use but provide limited clinical context, so DHCS will need to make method choices about attribution (which visits count), modality classification, and how to define a ‘new’ versus ‘established’ patient for telehealth claims.
Those choices will materially affect findings and how stakeholders interpret disparities.
Disaggregation introduces both analytic value and practical constraints. Small cell sizes will require suppression or aggregation to protect privacy, which can obscure the very disparities the law seeks to illuminate.
Using indices like the Healthy Places Index helps approximate social determinants without building new data collection, but those indices are proxies that can mask neighborhood heterogeneity. Finally, the bill requires DHCS to identify outcome and population health elements for future inclusion but does not define metrics or timelines, leaving open whether future reports will reliably connect telehealth use to clinical outcomes.
Absent dedicated funding, departmental capacity limits could shape what is actually reported more than statutory intent does.
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